Income from immovable property may be taxed in the State where the property is located under the treaty rules. Income from immovable property derived by a resident of one Contracting State from property situated in the other Contracting State may be taxed in the State where the property is located; this includes income from agriculture or forestry and from direct use, letting or other use. 'Immovable property' is defined by the law of the State where situated and includes accessories, agricultural livestock and equipment, landed-property rights, usufruct and payments for working mineral deposits and other natural resources, while ships, boats and aircraft are excluded. The rule applies to enterprise income and income used for independent personal services.
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Provisions expressly mentioned in the judgment/order text.
Income from immovable property may be taxed in the State where the property is located under the treaty rules.
Income from immovable property derived by a resident of one Contracting State from property situated in the other Contracting State may be taxed in the State where the property is located; this includes income from agriculture or forestry and from direct use, letting or other use. "Immovable property" is defined by the law of the State where situated and includes accessories, agricultural livestock and equipment, landed-property rights, usufruct and payments for working mineral deposits and other natural resources, while ships, boats and aircraft are excluded. The rule applies to enterprise income and income used for independent personal services.
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